The U.S. Department of Justice (“DOJ”) announced last week that settlements and judgments under the False Claims Act (“FCA”) exceeded $6.8 billion in fiscal year 2025—a record-breaking figure and the highest in a single year in the history of the FCA. DOJ’s announcement underscores the government’s continued commitment to FCA enforcement, particularly in health care, while expanding enforcement resources to address tariff and customs avoidance, military procurement fraud, and cybersecurity compliance.
Below is a summary of the key takeaways from DOJ’s press release and accompanying fact sheet and statistics table, along with our key insights for companies trying to anticipate what lies ahead.
Highest Number of Qui Tam Lawsuits: Fiscal year 2025 was record-breaking for qui tam actions. Whistleblowers filed 1,297 such lawsuits—the highest number in a single year—breaking the prior record of 980 set in fiscal year 2024. Although the government also opened 401 investigations of its own, including in areas announced as Administration policy objectives, qui tam lawsuits (not DOJ-initiated investigations) continue to generate more than three-quarters of new FCA matters.
Qui Tam-Based Recoveries: Over $5.3 billion of the total recoveries arose from qui tam actions and earlier-filed qui tam suits. This represents nearly 78% of the total $6.8 billion recovered, underscoring the outsized role whistleblowers play in FCA enforcement. Indeed, of the $5.3 billion in recoveries...
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